State Street fined US$7.5m by OFAC over invoice date changes to evade Russia sanctions

In the United States, Directive 1 under Executive Order 13662 bars US persons from dealing in new debt of proscribed entities over 90, 30 or 14 days' maturity, according to date of issuance. Importantly, sending out an invoice counts as dealing in debt under Directive 1.

In the United States, Directive 1 under Executive Order 13662 bars US persons from dealing in new debt of proscribed entities over 90, 30 or 14 days' maturity, according to date of issuance. Importantly, sending out an invoice counts as dealing in debt under Directive 1.